2011-03-25_REVISION - C1981012 (2)

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03/2512011 09:35 FAH 7192275297 OOWCOS 1a002/005 STATE OF COLORAW J wo *hn W. Hicksnleoper, Governer CQ DEPARTMENT OF NATURAL RESOURCES DIVISION OF WILDLIFE ' AM EQUAL OPPORTL9,9TYEMPLOYER j Thomas E. Remington, Director of ' ?utheest Reciore For ltldlrfe- 4255 Sinton Road For People Colorado Springs, Co 50947 Telephone. (719)227-524D FAX: (719)227-5297 www, wlldifib. state. co. us March 1, 2011 Mr. Kent A. Gorham Environmental Protection Specialist Division of Reclamation, Mining and Safety 1313 Sherman St., Room 215 Denver, CO 80203 Re:. CROW review and comments pertuiiaing to subsidence and subsidence control - New Elk Mine (Permit No. C-1981-012), Permit Revision Application No. 2 (PR 2), and Mine Revision plan bear Mr. Gorham: The Colorado Division of Wildlife (CROW) has reviewed your letter, dated February 14, 2011, regarding potential underground mine subsidence relating to ccW mine operations at the New Elk Mine (NECC) under the Hosque del Oso State Wildlife Area (SWA., Our comments relate to specific parts of the Subsidence Control, Monitoring, and Mitigation Plan (Exhibit 24), and only to those operations of the NECC mine which underlie the SWA. The 29,940 we SWA was purchased by the Division of wildlife in 1999. All hard minerals, including coal, were acquired while oil and gas rights were severed prior to the states acquisition. All surface use, disturbances, damage reimbursements and reclamation due to ongoing gas operations are managed under a separate Surface Use Agreement (SUA). The states management emphasis has been to maintain and enhance wildlife habitat while providing for compatible public uses, The SWA plays a strategic role in the management of wildlife in the Upper Purgatoire Basin. By virtue of its extent across a broad elevational range and contiguity with private lands, the SWA has significant importance iR the management and protection of important wildlife species. Any and all actions, leases or agreements which may arise from the use of the surface and mineral interest must meet certain criteria; primarily being no net loss to the functionality of the property for wildlife, or direct impacts to wildlife related recreation. The health of the significant wildlife resources will always take precedence over all surface disturbances, leases and contracts; including, but not limited to the NECC lease. The CDOWs primary concern relate to the mitigation recommendations in the Subsidence Control, Monitoring, and Mitigation Plan developed by Agapito Associates, inc. (AA1 Plan) for Cline Mining Corp. CROW respectfully offers our comments constrictively snd in the vein of supporting the new mining operations under the SWA. DEPARTMENT OF NATURAL RESOURCES, Mike 10ng. Emm" DirecW WILDUFF COMMISSION, Tim Gleam. Chair. Robert Streeter, vice Chair. Marc Smith. Se mnary Members, DaNid R. Brougham • Da nnk Buechler • Don hee Farris • Aran Jones . John Singletary . Dwn Wing5W Ex Offim Members, Mu Km and John Sakm